Read the CySEC Circular C793
Memo #43-2026
CySEC Circular No: C793
Date: 07/08/2026
Subject: Liquidity Risk Management- The revised framework introduced by the amending Directive (EU) 2024/927
Purpose: To draw the attention of CUCITS MCs and CAIFMs to the significant amendments introduced to the European regulatory framework in relation to liquidity risk management and liquidity management tools.
In Summary:
CySEC has issued the Circular C793 on 06/08/2026 to draw the attention of Cyprus UCITS Management Companies and Self-Managed Cyprus UCITS (‘CUCITS MCs’) and Cyprus Alternative Investment Fund Managers and Self-Managed Cyprus AIFs (‘CAIFMs’) to the significant amendments introduced to the European regulatory framework in relation to liquidity risk management and liquidity management tools.
In particular, CySEC draws attention to the amendments introduced by Directive (EU) 2024/927, which amended Directive 2011/61/EU on Alternative Investment Fund Managers and Directive 2009/65/EC on UCITS, in relation to liquidity risk management (among others).
CySEC also draws the attention of the above mentioned Regulated Entities to the ESMA Guidelines on liquidity management tools of UCITS and open-ended AIFs, as well as to the relevant Regulatory Technical Standards (‘RTSs’), which further specify the characteristics of liquidity management tools.
CySEC reminds that on 06/05/2026 issued the Circular C776 to inform the above mentioned Regulated Entities of the ESMA Guidelines on Liquidity Management Tools (LMTs) for UCITS and open-ended AIFs and their adoption by CySEC through their incorporation into its supervisory practices and regulatory approach.
CySEC notes that the RTSs specifying the characteristics of LMTs, supplementing the AIFMD and UCITS Directives (i.e Delegated Regulations (EU) 2026/465 and (EU) 2026/466, respectively), these are binding in their entirety and directly applicable in all Member States and their relevant markets (i.e. do not need to be explicitly adopted).
The RTS apply as of 16/04/2026. In line also with the ESMA Guidelines, UCITS and AIFs established on or after that date are expected to comply immediately, while UCITS and AIFs established before that date, benefit from the applicable transitional arrangements until 16/04/2027.
CySEC expects the above mentioned Regulated Entities and their Boards of Directors to take an active and timely role in assessing and implementing the Liquidity Risk Management requirements as amended. In particular, CyIFMs should perform a documented gap analysis of their existing liquidity risk management frameworks, policies, procedures, fund documentation, systems and operational arrangements against the requirements of the RTS, the ESMA Guidelines and CySEC’s relevant guidance. In accordance with C793, CySEC expects the above mentioned Regulated Entities to maintain adequate records evidencing the assessments performed, decisions taken and measures implemented, and may request such evidence in the context of its supervisory activities.
Read the CySEC Circular C793
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